Data Protection & Access to Information
Our business will comply with all statutory requirements of the Data Protection Act by registering all personal data held on its computer and/or related electronic equipment and by taking all reasonable steps to ensure the accuracy and confidentiality of such information.
The Data Protection Act protects individuals’ rights concerning information about them held on computer. Anyone processing personal data must comply with the eight principles of good practice. Data must be:
- fairly and lawfully processed.
- processed for limited purposes.
- adequate, relevant and not excessive.
- accurate and not kept longer than necessary.
- processed in accordance with the data subject’s rights.
- not transferred to countries without adequate protection.
This policy is operational from 25 May 2018. The purpose of this policy is to enable us to:
- Comply with our legal, regulatory and corporate governance obligations and good practice.
- Gather information as part of investigations by regulatory bodies or in connection with legal proceedings or requests.
- Ensure business policies are adhered to (such as policies covering email and internet use).
- Fulfill operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information and security vetting.
- Investigate complaints.
- Check references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments.
- Monitor staff conduct, disciplinary matters.
- Market our business.
- Improve services.
This policy applies to information relating to identifiable individuals e.g. staff, applicants, former staff, clients, suppliers and other third party contacts.
- Comply with both the law and good practice.
- Respect individuals’ rights.
- Be open and honest with individuals whose data is held.
- Provide training and support for staff who handle personal data, so that they can act confidently and consistently.
We recognise that our first priority under the GDPR is to avoid causing harm to individuals. In the main this means:
- Complying with your rights.
- Keeping you informed about the data we hold, why we hold it and what we are doing with it.
- Keeping information securely in the right hands, and;
- Holding good quality information.
Secondly, GDPR aims to ensure that the legitimate concerns of individuals about the ways in which their data may be used are taken into account. In addition to being open and transparent, we will seek to give individuals as much choice as is possible and reasonable over what data is held and how it is used. This includes the right to erasure where data is no longer necessary and the right to rectification where the data is incorrect. Full details are available in the Privacy Notice issued at the point of gathering the data.
We have identified the following potential key risks, which this policy is designed to address:
- Breach of confidentiality (information being given out inappropriately).
- Insufficient clarity about the range of uses to which data will be put — leading to Data Subjects being insufficiently informed.
- Failure to offer choice about data use when appropriate.
- Breach of security by allowing unauthorised access.
- Failure to establish efficient systems of managing changes, leading to personal data being not up to date.
- Harm to individuals if personal data is not up to date.
- Insufficient clarity about the way personal data is being used.
- Failure to offer choices about use of contact details for staff, clients workers or employees.
In order to address these concerns, to accompany this policy, we have an accompanying Information Security Policy and we will issue Privacy Notices to explain what data we have, why we have it and what we will do with it. The Privacy Notice will also explain the data subjects rights. We will offer training to staff where this is necessary and appropriate in the circumstances to ensure compliance with GDPR. Such training will vary according to the role, responsibilities and seniority of those being trained.
We aim to keep data only for so long as is necessary which will vary from according to the circumstances.
We have no intention to transfer data internationally.
Significant breaches of this policy will be handled under the Company’s disciplinary procedures which may amount to gross misconduct.
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